The Court of Appeal decision in Christianuyi and HMRC’s subsequent spotlight signals HMRC’s intention to use the managed service company (MSC) legislation to target small accountancy advisers and their clients. Staffing agencies and end users that encouraged contractors to work via personal service companies will also be concerned about the possible transfer of tax debt. The court interpreted the MSC legislation more widely than expected, paving the way for HMRC to target arrangements previously thought to be low risk. Advisers should revisit past MSC advice, and agency/hirer ‘encouragers’ should review their practices, to re-assess the risk in light of this case.
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The Court of Appeal decision in Christianuyi and HMRC’s subsequent spotlight signals HMRC’s intention to use the managed service company (MSC) legislation to target small accountancy advisers and their clients. Staffing agencies and end users that encouraged contractors to work via personal service companies will also be concerned about the possible transfer of tax debt. The court interpreted the MSC legislation more widely than expected, paving the way for HMRC to target arrangements previously thought to be low risk. Advisers should revisit past MSC advice, and agency/hirer ‘encouragers’ should review their practices, to re-assess the risk in light of this case.
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